Dependent personal services taxable in resident state unless employment abroad; exceptions for short stays, non-resident employer, no permanent establishment

Article 15 provides that remuneration from employment is taxable only in the employee's state of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax it. However, exclusive taxation by the state of residence applies where the employee's presence abroad is limited, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base in that other State. Wages from employment on ships or aircraft in international traffic may be taxed in the enterprise's State.

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